A TECHNICAL PUBLICATION OF ASSE’S ENGINEERING PRACTICE SPECIALTY ByDesign www.asse.org AMERICAN SOCIETY OF SAFETY ENGINEERS Prevention through Design: Addressing Occupational Risks in the Design & Redesign Processes By Fred A. Manuele, P.E., CSP T he National Institute for Safety and Health (NIOSH) held a workshop in July 2007 to obtain the views of a variety of stakeholders on a major initiative to “create a sustainable national strategy for Prevention through Design.” Some of the participants expressed the view that the long-term impact of the NIOSH initiative could be “transformative,” meaning that a fundamental shift could occur in the practice of safety resulting in greater emphasis being given to the higher and more effective decision levels in the hierarchy of controls. For this initiative, the NIOSH Mission is: To reduce the risk of occupational injury and illness by integrating decisions affecting safety and health in all stages of the design process. To move toward fulfillment of its mission, NIOSH Director Dr. John Howard has said that: One important area of emphasis will be to examine ways to create a demand for graduates of business, architecture, and engineering schools to have basic knowledge in occupational health and safety principles and concepts. The Prevention through Design (PtD) initiative is based on the premise, as stat- ed in NIOSH literature, that “One of the best ways to prevent and control occupational injuries, illnesses, and fatalities is to design out or minimize hazards and risks early in the design process.” A definition of PtD was written that limited the activity to “early in the design process.” At the July 2007 workshop, a large number of participants wanted the concept extended to include the redesign activities in which they are participants. A revised definition was written. Prevention through Design (PtD): Addressing occupational safety and health needs in the design and redesign processes to prevent or minimize the work-related hazards and risks associated with the construction, manufacture, use, maintenance, and disposal of facilities, materials and equipment. Enthusiasm for additional knowledge of prevention through design principles and practices was significant. Several attendees said it would be helpful if a regulation or a standard was in place that sets forth the principles and the methodologies to address hazards and risks in the design and redesign processes. The probability that OSHA could promulgate a T he Engineering Practice Specialty (EPS) has developed this special issue of ByDesign to highlight the importance of designing out or minimizing hazards and risks early in the design and redesign processes to prevent and control occupational injuries, illnesses and fatalities. Fred A. Manuele, P.E., CSP, president of Hazards Limited, has authored this issue’s featured article, “Prevention through Design: Addressing Occupational Risks in the Design and Redesign Processes.” EPS believes this article effectively explains the core of the prevention through design concept, and we hope that such concepts will lead to established principles, methodologies and standards for controlling hazards and risks during the design and redesign processes. Bruce L. Rottner Engineering Practice Specialty Administrator regulation or a standard on Prevention through Design is remote. It is more probable that an ANSI standard could be developed and approved, but that could take several years. For example, ANSI/AIHA Z10-2005, the Occupational Health and Safety Management Systems Standard, was published 6 years after the secretariat received ANSI approval to begin work on it. Assume that the NIOSH initiative, which is a several-year undertaking, is successful. Since hazards analyses and risk assessments are the core of the PtD concept, the impact on safety practitioners with respect to their knowledge needs will be significant. As a primer, this paper is written to address those needs. Promoting the acquisition of knowledge of safety through design/prevention continued on page 2 continued from page 1 through design concepts is in concert with the ASSE position paper on designing for safety approved by the Board of Directors in 1994. The opening paragraph of that paper reads as follows. Designing for Safety (DFS) is a principle for design planning for new facilities, equipment, and operations (public and private) to conserve human and natural resources, and thereby protect people, property and the environment. DFS advocates systematic process to ensure state-of-the-art engineering and management principles are used and incorporated into the design of facilities and overall operations to assure safety and health of workers, as well as protection of the environment and compliance with current codes and standards. 1.0 Scope & Purpose 1.1 This paper provides guidance on incorporating decisions pertaining to occupational risks into design and redesign processes, including consideration of the life cycle of facilities, materials and equipment. 1.2 The goals of applying prevention through design principles are to: 1.2.1 Achieve safety, defined as that state for which the risks are at an acceptable level, and 1.2.2 Minimize the occurrence of occupational injuries, illnesses and fatalities. Since this paper is prompted by a NIOSH initiative, and since NIOSH is exclusively an occupational safety and health entity, the scope of this paper relates principally to the elimination, reduction or control of occupational risks. But, it would be folly to ignore the fact that the events or exposures that have the potential to result in occupational injuries and illnesses can also result in damage to property and business interruption, and damage to the environment. Reference is made in several places in this paper to those additional loss potentials. Thus, the definition of safety through design, a broader definition than that for PtD, is included in the list of definitions. 2.0 Application 2.1 While these guidelines apply to all occupational settings, the focus is on providing assistance to managements, design engineers, and safety professionals at smaller locations, say with 500 or fewer employees. 2.2 These guidelines apply to the three major elements in the practice of safety: 2.2.1 Pre-operational, in the design process – where the opportunities are greatest and the costs are lower for hazard and risk avoidance, elimination, or control. 2.2.2 In the operational mode – where hazards are to be eliminated or controlled and risks reduced before their potentials are realized and hazards-related incidents or exposures occur. 2.2.3 Post-incident as investigations are made of hazards-related incidents and exposures to determine causal factors and risk reduction measures. 3.0 Definitions Acceptable risk: That risk for which the probability of a hazard-related incident or exposure occurring and the severity of harm or damage that may result are as low as reasonably practicable, and tolerable in the setting considered. (This definition incorporates the ALARP concept.) ALARP: That level of risk which can be further lowered only by an increment in resource expenditure that cannot be justified by the resulting decrement of risk. Design: The process of converting an idea or market need into the detailed information from which a product or technical system can be produced. Hazard: Potential for harm. Hazards include all aspects of technology and activity that produce risk. Hazards include the characteristics of things (equipment, dusts) and the actions or inactions of people. Hazard analysis: A process that commences with recognition of a hazard and proceeds into an estimate of the severity of harm or damage that could result if a hazard’s potential is realized and a hazard-related incident or exposure occurs. Hierarchy of controls: A systematic way of thinking, considering steps in a ranked and sequential order, to choose the most effective means of eliminating or reducing hazards and the risks that derive from them. Life cycle: The phases of the facility, equipment and material, including: design 2 Special Issue Prevention through Design Engineering Practice Specialty ByDesign OFFICERS ADMINISTRATOR Bruce L. Rottner 201.287.1766 [email protected] ASSISTANT ADMINISTRATOR J. Nigel Ellis 302.571.8470 [email protected] NEWSLETTER EDITOR J. Nigel Ellis [email protected] COMMITTEES AWARDS & HONORS Open BODY OF KNOWLEDGE Dennis Neitzel [email protected] CONFERENCES & SEMINARS Open MEMBERSHIP DEVELOPMENT Gina Mayer-Costa [email protected] NOMINATIONS John W. Mroszczyk [email protected] WEBSITE DEVELOPMENT Magdy Akladios [email protected] STAFF LIAISON Rennie Heath 847.768.3436 [email protected] NEWSLETTER DESIGN & PRODUCTION Susan Carlson ASSE headquarters staff [email protected] ByDesign is a publication of ASSE’s Engineering Practice Specialty, 1800 E. Oakton St., Des Plaines, IL 60018, and is distributed free of charge to members of the Engineering Practice Specialty. The opinions expressed in articles herein are those of the author(s) and are not necessarily those of ASSE. Technical accuracy is the responsibility of the author(s). Please send address changes to the address above; fax to (847) 768-3434; or send via e-mail to [email protected]. and construction, operation, maintenance, and disposal. Prevention through Design: Addressing occupational safety and health needs in the design and redesign processes to prevent or minimize the work-related hazards and risks associated with the construction, manufacture, use, maintenance, and disposal of facilities, materials and equipment. Probability: The likelihood of an incident or exposure occurring that could result in harm or damage—for a selected unit of time, events, population, items or activity considered. Residual risk: The risk remaining after preventive measures have been taken. No matter how effective the preventive actions, there will always be residual risk if a facility or operation continues to exist. Risk: An estimate of the probability of a hazards-related incident or exposure occurring and the severity of harm or damage that could result. Risk assessment: A process that commences with hazard identification and analysis, through which the probable severity of harm or damage is established, and concludes with an estimate of the probability of the incident or exposure occurring. Safety: That state for which the risks are at an acceptable level, and tolerable in the setting being considered. Safety through Design: The integration of hazard analysis and risk assessment methods early in the design and redesign processes and taking the actions necessary so that the risks of injury or damage are at an acceptable level. This concept encompasses facilities, hardware, equipment, tooling, materials, layout and configuration, energy controls, environmental concerns, and products. Severity: The extent of harm or damage that could result from a hazard-related incident or exposure. 4.0 Responsibility 4.1 Location management shall provide the leadership to institute and maintain a policy and procedures within the design and redesign processes through which: 4.1.1 Hazards are identified and analyzed. 4.1.2 Risks deriving from identified hazards are assessed and prioritized. 4.1.3 Risks are reduced to an acceptable level through the application of the hierarchy of controls described in Section 13. 4.2 These methods are to be applied when: 4.2.1 New facilities, equipment, and processes are acquired. 4.2.2 Alterations are made in existing facilities, equipment, and processes. 4.2.3 Incident investigations are made. 4.3 All who have design responsibilities, the operations personnel who will be affected, and safety practitioners are to be involved as participants in the decision making. 4.4 In carrying out these responsibilities, management may: 4.4.1 Designate qualified in-house personnel to identify and analyze hazards and assess the risks deriving from them for operations in place. 4.4.2 Engage independent contractors with capabilities in hazard identification and analysis and risk assessments as consultants to assist with respect to operations in place and in the acquisition of new facilities, equipment or materials. 4.4.3 Enter into arrangements with suppliers of newly acquired facilities, equipment or materials to fulfill these responsibilities, as in 5.0. applicable standards, among which is ISO 12100-1, Safety of Machinery: Basic concepts, general principles for design; Part 1, Basic terminology, methodology. That standard requires that risk assessments be made as outlined in ISO 14121, Safety of Machinery: Principles for risk assessments. 5.1.5 Arrange for persons on the organization’s staff (design engineers, safety practitioners, and maintenance personnel) to visit the supplier of equipment that the staff may consider hazardous or for which design specifications have been provided the supplier before the equipment is shipped to assure that safety needs have been met. 5.1.6 See that a test run of the equipment is made during that visit. 5.1.7 Have an additional validation test run made after the equipment has been installed during which safety personnel or others sign off that safety needs have been met. 5.0 Relationships with Suppliers 6.0 Making Hazards Analyses & Risk Assessments 5.1 A large majority of employers will not have design or technical staffs in depth to fulfill the requirements of 4.0. Thus, to avoid bringing hazards and risks into the workplace when new facilities, equipment and processes are considered and to assure that hazards and risks are properly considered when alterations are made in existing operations by contractors, location management should: 5.1.1 Establish its design specifications and objectives. 5.1.2 Have an in-depth dialogue with suppliers and contractors on the expected use of the facilities, equipment and processes. 5.1.3 Include specifications in purchasing agreements and contracts for services to minimize bringing hazards and their related risks into the workplace. 5.1.4 Ask suppliers of services to attest that processes have been applied to identify and analyze hazards and to reduce the risks deriving from those hazards to an acceptable level. There is a precedent for such an arrangement. Manufacturers of equipment to go into a workplace in the European Community are required by International Organization for Standardization (ISO) standards to certify that they have met 6.1 For many hazards and the risks that derive from them, knowledge gained by management personnel, design engineers and safety practitioners through education and experience will lead to proper conclusions on how to attain an acceptable risk level without bringing teams of people together for discussion. 6.2 For more complex risk situations, it is vital to seek the counsel of experienced personnel at all levels who are close to the work or process. Reaching group consensus is a highly desirable goal. Sometimes, for what a safety professional considers obvious, achieving consensus is still desirable so that buy-in is obtained for the actions to be taken. 6.3 The goal of the risk assessment process is to achieve acceptable risk levels. The process is not complete until acceptable risk levels are achieved. 6.4 A general guide follows in 7.0 on how to make a hazard analysis and how to extend the process into a risk assessment. 6.5 Whatever the simplicity or complexity of the hazard/risk situation, and whatever analysis method is used (there are many), the thought and action process in 7.0 applies. continued on page 4 By Design 3 continued from page 3 7.0 The Hazard Analysis & Risk Assessment Process Although the focus in this paper is on eliminating, reducing, and controlling occupational risks, the process outlined here is equally applicable in avoiding injury to the public, damage to property and business interruption, damage to the environment, and product liability incidents. 7.1 Establish the analysis parameters. Select a manageable task, system, process or product to be analyzed, and establish its boundaries and operating phase (e.g., standard operation, maintenance, startup). 7.1.1 Define its interface with other tasks or systems, if appropriate. 7.1.2 Determine the scope of the analysis in terms of what can be harmed or damaged—people (employees, the public); property; equipment; productivity; the environment. 7.2 Identify the hazard. A frame of thinking should be adopted that gets to the bases of causal factors, which are hazards. These questions should be asked: 7.2.1 What are the aspects of technology or activity that produce risk? 7.2.2 What are the characteristics of things (equipment, dusts) or the actions or inactions of people that present a potential for harm? 7.2.3 Depending on the complexity of the hazardous situation, some or all of the following may apply. a) Use intuitive engineering and operational sense. b) Examine system specifications and expectations. c) Review codes, regulations, and consensus standards. d) Interview current or intended system users or operators. e) Consult checklists. f) Review studies from similar systems. g) Consider the potential for unwanted energy releases. h) Take into account possible exposures to hazardous environments. i) Review historical data – industry experience, incident investigation reports, OSHA and National Safety Council data, manufacturer’s literature. j) Brainstorm. 7.3 Consider the failure modes. Define the possible failure modes that would result in realization of the potentials of the hazards. Both the intentional and foreseeable misuse of facilities, equipment, and materials should be considered. Ask: 7.3.1 What circumstances can arise that would result in the occurrence of an undesirable event? 7.3.2 What controls are in place that mitigate against the occurrence of such an event or exposure? 7.3.3 How effective are the controls? 7.3.4 Can controls be maintained easily? 7.3.5 Can controls be defeated easily? 7.4 Determine the frequency and duration of exposure. For each harm or damage category selected for the scope of the analysis (people, property, business interruption etc.), estimate the frequency and duration of the exposure to the hazard. This is a very important part of this exercise. For instance, in a workplace situation, more judgments than one might realize will be made in this process. Ask: 7.4.1 How often is a task performed? 7.4.2 How long is the exposure period? 7.4.3 How many people are exposed? 7.4.4 What property or aspects of the environment are exposed? 7.5 Assess the severity of consequences. On a subjective basis, the goal is to decide on the worst credible consequences should an incident occur, not the worst conceivable consequence. (In Section 11.0, see Tables 7 and 8 for examples of severity categories.) Historical data can be of great value as a baseline. Informed speculations are made to establish the consequences of an incident or exposure. Consider the: 7.5.1 Number of injuries or illnesses and their severity and fatalities. 7.5.2 Value of property or equipment damaged. 7.5.3 Time for which the business will be interrupted and productivity will be lost. 7.5.4 Extent of environmental damage. When the severity of the outcome of a hazards-related incident or exposure is determined, a hazard analysis has been completed. 7.6 Determine occurrence probability. Extending the hazard analysis into a risk assessment requires the one additional step of estimating the likelihood or probability of a hazardous event or exposure occurring. (In Section 11.0, see Tables 5 and 6 for possible probability categories.) 7.6.1 Unless empirical data are avail- 4 Special Issue Prevention through Design able (and that would be a rarity), the process for selecting the probability that an incident or exposure will occur is subjective. 7.6.2 For the more complex hazardous situation, brainstorming with knowledgeable people is necessary. 7.6.3 To be meaningful, probability must be related to an interval base of some sort, such as a unit of time or activity, events, units produced, or the life cycle of a facility, equipment, process, or a product. 7.7 Define the risk. Conclude with a statement that includes the: 7.7.1 Probability of a hazards-related incident or exposure occurring. 7.7.2 Expected severity of adverse results. 7.7.3 Risk category. (For example, high, serious, moderate or low.) 7.7.4 A risk assessment matrix should be used to identify risk categories. A matrix assists in communicating with the decision makers on the risk levels. (See Section 9.0 for examples of risk assessment matrices.) 7.8 Rank risks in priority order. A risk ranking system should be adopted so that priorities can be established. 7.8.1 Since the risk assessment exercise is subjective, the risk ranking system would also be subjective. 7.8.2 Prioritizing risks gives management the knowledge needed on the potentials risks produce for harm or damage so that intelligent resource allocations can be made for their elimination or reduction. 7.9 Develop remediation proposals. When the results of the risk assessment indicate that risk elimination, reduction, or control measures are to be taken to achieve acceptable risk levels: 7.9.1 Alternate proposals for the design and operational changes necessary to achieve an acceptable risk level would be recommended. 7.9.2 The actions as shown in the hierarchy of controls (Section 13.0) would be the base upon which remedial proposals are made, in the order of their effectiveness. 7.9.3 Remediation cost for each proposal would be determined and an estimate would be given of its effectiveness in achieving risk reduction. 7.9.4 Risk elimination or reduction methods would be selected and implemented to achieve an acceptable risk level. 7.10 Follow up on actions taken. TABLE 1 Risk Assessment Matrix Although a hazard analysis and a risk assessment results from applying the Occurrence Severity of Consequence steps in the preceding outline, good manCatastrophic Critical Marginal Negligible Probability agement requires that the effectiveness of Frequent High High Serious Medium the actions taken be determined. FollowProbable High High Serious Medium up activity would determine that the: Occasional High Serious Medium Low 7.10.1 The hazard/risk problem was Remote Serious Medium Medium Low resolved, only partially resolved, or not Improbable Medium Medium Medium Low resolved. 7.10.2 Actions taken did or did not create new hazards. TABLE 2 Risk Assessment Matrix: Numerical Gradings 7.10.3 If an acceptable risk level is not achieved, Severity Levels Occurrence Probabilities & Values or if new hazards are & Values Frequent (5) Likely (4) Occasional (3) Seldom (2) Unlikely (1) introduced, the risk is to Catastrophic(5) 25 20 15 10 5 be re-evaluated and other Critical (4) 20 16 12 8 4 countermeasures are to Marginal (3) 15 12 9 6 3 be proposed. Negligible (2) 10 8 6 4 2 7.11 Document the Insignificant (1) 5 4 3 2 1 results. Documentation, Very high risk: 15 or greater High risk: 9 to 14 Moderate risk: 4 to 8 Low risk: Under 4 whether compiled under the direction of location management or by the 8.2 If the residual risk is not acceptrisks, and to effectively allocate mitigaprovider of equipment or services, should able, the action outline set forth in the tion resources. Safety practitioners must include comments on the: foregoing hazard analysis and risk assess- understand that definitions of the terms 7.11.1 Risk assessment method(s) used. ment process (7.0) would be applied used for incident probability and severity 7.11.2 Hazards identified. again. (Addendum A is an outline of one and for risk levels vary greatly in the 7.11.3 Risks deriving from the hazards. company’s risk assessment process.) many risk assessment matrices in use. 7.11.4 Reduction measures taken to 9.2 Thus, safety practitioners should attain acceptable risk levels. 9.0 Risk Assessment Matrices create and obtain broad approval for a risk 9.1 A risk assessment matrix provides assessment matrix that is suitable to the a method to categorize combinations of 8.0 Residual Risk hazards and risks with which they deal. probability of occurrence and severity of 8.1 Residual risk is the risk remaining 9.3 Three examples of risk assessment harm, thus establishing risk levels. A after preventive measures have been matrices are provided here to serve as refmatrix helps in communicating with decitaken. No matter how effective the preerences. sion makers on risk reduction actions to ventive actions, there will always be 9.3.1 Table 1 is an adaptation from a be taken. Also, risk assessment matrices residual risk if an activity continues. matrix in MIL-STD-882 D, the Departcan be used to compare and prioritize Attaining zero risk is not possible. ment of Defense Standard Practice for System Safety. (MIL-STD-882, first issued in 1969, is the grandfather of risk TABLE 3 Risk Assessment Matrix: ANSI B11.TR3-2000 assessment matrices.) Occurrence Severity of Harm 9.3.2 This second exhibit of a risk Catastrophic Serious Moderate Minor Probability assessment matrix (Table 2) is a composite Very likely High High High Medium of matrices that include numerical values Likely High High Medium Low for probability and severity levels that are Unlikely Medium Medium Low Negligible transposed into risk scorings. It is presented Remote Low Low Negligible Negligible here for people who prefer to deal with numbers rather than qualitative indicators. (A word of caution: The numbers are arrived at judgmentally and are qualitative.) TABLE 4 Management Decision Levels 9.3.3 Table 3 is taken from the Risk Risk Category Remedial Action or Acceptance Estimation Matrix that appears in ANSI High Operation not permissible. B11.TR3-2000, the ANSI Technical Report titled Risk Assessment and Risk Serious Remedial action to have high priority. Reduction: A Guide to Estimate, Evaluate Medium Remedial action to be taken in appropriate time. and Reduce Risks Associated with Low Risk is acceptable; remedial action discretionary. continued on page 6 By Design 5 continued from page 5 Machine Tools. It is the basis on which the risk assessments shown in Addendum B were made. 10.0 Management Decision Levels 10.1 Remedial action or acceptance levels must be attached to the risk categories to permit intelligent management decisionmaking. Table 4 provides a basis for review and discussion. Other safety practitioners who craft risk assessment matrices may have differing ideas about acceptable risk levels and the management actions to be taken in a given risk situation. 11.0 Descriptions of the Terms: Probability & Severity 11.1 There is no one right method in selecting probability (likelihood) and severity categories and their descriptions, and many variations are in use. Examples in Tables 5 through 8 show variations in the terms and their descriptions as used in applied risk assessment processes for probability of occurrence and severity of consequence. Hazard Identification & Evaluation Techniques for System Safety Applications.” In the System Safety Analysis Handbook, 101 methods are described. Brief descriptions are given here of purposely selected hazard analysis techniques. If a safety practitioner understands all of them and is capable of bringing them to bear in resolving hazards and risk situations, he or she will be exceptionally well qualified to give counsel on risk assessments. As a practical matter, having knowledge of three risk assessment concepts will be sufficient to address most risk situations. They are initial hazard analysis and risk assessment; the whatif/checklist analysis methods; and failure mode and effects analysis (FMEA). 12.2 It is important to understand that each of those techniques complements, rather than supplants, the others. Selecting the technique or a combination of techniques to be used to analyze a hazardous situation requires good judgment based on knowledge and experience. 12.3 Qualitative rather than quantitative judgments will prevail. For all but the complex risks, qualitative judgments will be sufficient. 12.0. Descriptions of Hazards Analyses & Risk Assessment Techniques 12.4 Sound quantitative data on incident and exposure probabilities is seldom available. Many quantitative risk assess12.1 Over the past 40 years, many hazard analysis and risk assessment tech- ments are really qualitative risk assessments because so many judgments must niques have been developed. For exambe made in the process to decide on the ple, Pat Clemens gave brief descriptions probability levels selected. of 25 techniques in “A Compendium of 12.5 Preliminary TABLE 5 Probability Descriptions: Example A Hazard Descriptive Word Probability Descriptions Analysis Frequent Likely to occur repeatedly (PHA): Initial Probable Likely to occur several times Hazard Occasional Likely to occur sometime Analysis and Remote Not likely to occur Risk Assessment Improbable So unlikely, can assume occurrence 12.5.1 The will not be experienced origin of the PHA techTABLE 6 Probability Descriptions: Example B nique is in system safety. It Descriptive Word Probability Descriptions was to identify Frequent Could occur annually and evaluate Likely Could occur once in 2 years hazards in the Possible Not more than once in 5 years very early Rare Not more than once in 10 years stages of the Unlikely Not more than once in 20 years design process. 6 Special Issue Prevention through Design However, in actual practice the technique has attained much broader use. The principles on which preliminary hazards analyses are based are used not only in the initial design process, but also in assessing the risks of existing products or operations. Thus, the technique needs a new name: Initial Hazard Analysis and Risk Assessment. (Take note to avoid confusion, for OSHA’s Rule For Process Safety Management Of Highly Hazardous Chemicals and for EPA’s Risk Management Program for Chemical Accidental Release Prevention, PHA stands for process hazard analysis.) 12.5.2 Headings on initial hazard analysis forms will include the typical identification data: date, names of evaluators, department and location. The following information is usually included in an initial hazard analysis process. a) Hazard description, sometimes called a hazard scenario. b) Description of the task, operation, system, subsystem or product analyzed. c) Exposures to be analyzed: people (employees, the public); facility, product or equipment loss; operation down time; environmental damage. d) Probability interval to be considered: unit of time or activity; events; units produced; life cycle. e) Risk assessment code, using the agreed upon risk assessment matrix. f) Remedial action to be taken, if risk reduction is needed. 12.5.3 A communication accompanies the analysis, indicating the assumptions made and the rationale for them. Comment would be made on the assignment of responsibilities for the remedial actions to be taken and expected completion dates. An initial hazard analysis and risk assessment worksheet appears as Addendum B in this paper, courtesy of Design Safety Engineering Inc. 12.6 What-if analysis 12.6.1 For a what-if analysis, a group of people (as little as two, but often several more) use a brainstorming approach to identify hazards, hazard scenarios, failure modes, how incidents can occur and their probable consequences. 12.6.2 Questions posed during the brainstorming session may commence with what-if, as in “What if the air conditioning fails in the computer room?” or may express general concerns, as in “I worry about the possibility of spillage TABLE 7 Severity Descriptions for Multiple Harm & Damage Categories: Example A Catastrophic Critical Marginal Negligible Death or permanent total disability, system loss, major property damage and business down time Permanent, partial or temporary disability in excess of 3 months, major system damage, significant property damage and downtime Minor injury, lost workday accident, minor system damage, minor property damage and little downtime First-aid or minor medical treatment, minor system impairment TABLE 8 Severity Descriptions for Multiple Harm & Damage Categories: Example B Catastrophic Critical Marginal Negligible One or more fatalities, total system loss, chemical release with lasting environmental or public health impact Disabling injury or illness, major property damage and business down time, chemical release with temporary environmental or public health impact Medical treatment or restricted work, minor subsystem loss or damage, chemical release triggering external reporting requirements First aid only, non-serious equipment or facility damage, chemical release requiring only routine cleanup without reporting and chemical contamination during truck offloading.” 12.6.3 All of the questions are recorded, and assigned for investigation. Each subject of concern is then addressed by one or more team members. They would consider the potential of the hazardous situation and the adequacy or inadequacy of risk controls in effect, suggesting additional risk reduction measures if appropriate. 12.7 Checklist analysis 12.7.1 Checklists are primarily adaptations from published standards, codes, and industry practices. There are many such checklists. They consist of questions pertaining to the applicable standards and practices, usually with a yes or no or not applicable response. Their purpose is to identify deviations from the expected, and thereby possible hazards. A checklist analysis requires a walk-through of the area to be surveyed. Checklists are easy to use and provide a cost-effective way to identify customarily recognized hazards. 12.7.2 Nevertheless, the quality of checklists depends on the experience of the people who develop them. Further, they must be crafted to suit particular facility/operations needs. If a checklist is incomplete, the analysis may not identify some hazardous situations. 12.8 What-if/checklist analysis 12.8.1 A what-if/checklist hazard analysis technique combines the creative, brainstorming aspects of the What-If method with the systematic approach of a Checklist. Combining the techniques can compensate for the weaknesses of each. 12.8.2 The what-if part of the process, using a brainstorming method, can help the team identify hazards that have the potential to be the causal factors for incidents, even though no such incidents have yet occurred. The checklist provides a systematic approach for review that can serve as an idea generator during the brainstorming process. Usually, a team experienced in the design, operation, and maintenance of the operation performs the analysis. 12.9 Hazard and operability analysis 12.9.1 The hazard and operability analysis (HAZOP) technique was developed to identify both hazards and oper- ability problems in chemical process plants. It has subsequently been applied to a wide range of industry processes and equipment. An interdisciplinary team and an experienced team leader are required. 12.9.2 In a HAZOP application, a process or operation is systematically reviewed to identify deviations from desired practices that could lead to adverse consequences. HAZOPs can be used at any stage in the life of a process. 12.9.3 HAZOPs usually require prework in gathering materials and a series of meetings in which the team, using process drawings, systematically evaluates the impact of deviations from the desired practices. The team leader uses a set of guide words to develop discussions. 12.9.4 As the team reviews each step in a process, recordings are made of: a) deviations; b) their causal factors; c) consequences should an incident occur; d) safeguards in place; e) required actions, or the need for more information to evaluate the deviation. 12.10 Failure modes & effects analysis 12.10.1 In several industries, failure modes and effects analyses (FMEA) have been the techniques of choice by design engineers for reliability and safety considerations. They are used to evaluate the ways in which equipment fails and the response of the system to those failures. 12.10.2 Although FMEA is typically made early in the design process, the technique can also serve well as an analysis tool throughout the life of equipment or a process. 12.10.3 An FMEA produces qualitative, systematic lists that include the failure modes, the effects of each failure, safeguards that exist, and additional actions that may be necessary. For example, for a pump, the failure modes would include fails to stop when required; stops when required to run; seal leaks or ruptures; and pump case leaks or ruptures. 12.10.4 Both the immediate effects and the impact on other equipment would be recorded. Generally, when analyzing impacts, the probable worst case is assumed and analysts would conclude that existing safeguards do or do not work. Although an FMEA can be made by one person, it is typical for a team to be appointed when there is complexity. continued on page 8 By Design 7 continued from page 7 12.10.5 In either case, the traditional process is similar, as in the following. a) Identify the item or function to be analyzed b) Define the failure modes c) Record the failure causes d) Determine the failure effects e) Enter a severity code and a probability code for each effect f) Enter a risk code g) Record the actions required to reduce the risk to an acceptable level 12.10.6 The FMEA process described here requires entry of probability, severity, and risk codes. A FMEA form on which those codes would be entered is provided here as Addendum C.(Good references explaining risk coding for FMEA purposes are the reference manual titled Potential Failure Mode and Effects Analysis issued by the Automotive Industry Action Group; and the semiconductor industry publication Failure Mode and Effects Analysis (FMEA): A Guide for Continuous Improvement for the Semiconductor Equipment Industry.) 12.11 Fault tree analysis 12.11.1 A fault tree analysis (FTA) is a top-down, deductive logic model that traces the failure pathways for a predetermined, undesirable condition or event, called the TOP event. An FTA can be carried out either quantitatively or subjectively. 12.11.2 It is emphasized that a subjective (or qualitative) analysis can produce suitable results, especially when quantitative numbers are not available. The FTA generates a fault tree (a symbolic logic model) entering failure probabilities for the combinations of equipment failures and human errors that can result in the accident. Each immediate causal factor is examined to determine its subordinate causal factors until the root causal factors are identified. 12.11.3 The strength of an FTA is its ability to identify combinations of basic equipment and human failures that can lead to an accident, allowing the analyst to focus preventive measures on significant basic causes. 12.11.4 An FTA has particular value when analyzing highly redundant systems and high-energy systems in which highseverity events can occur. For systems vulnerable to single failures that can lead to accidents, the FMEA and HAZOP techniques are better suited. 12.11.5 FTA is often used when another technique has identified a hazardous situation that requires more detailed analysis. Making a fault tree analysis of other than the simplest systems requires the talent of experienced analysts. 12.12 Management oversight and risk tree 12.12.1 All of the hazard analysis and risk assessment techniques previously discussed relate principally to the initial design process in the pre-operational mode, or to the redesign process to achieve risk reduction in the operational mode. Management Oversight and Risk Tree (MORT) is relative to the post-incident element of the practice of safety. 12.12.2 MORT was developed principally for incident investigations. In the Abstract for the Guide To Use Of The Management Oversight And Risk Tree, this is how MORT is described: MORT is a comprehensive analytical procedure that provides a disciplined method for determining the systemic causes and contributing factors of accidents. MORT directs the user to the hazards and risks deriving from both system design and procedural shortcomings (emphasis added). 12.2.3 MORT provides an excellent resource for the post-incident element of the practice of safety during which the hazard identification and analysis and risk assessment methods described here can be used. 13.0 Hierarchy of Controls 13.1 A hierarchy is a system of persons or things ranked one above the other. A hierarchy of controls provides a systematic way of thinking, considering steps in a ranked and sequential order, to choose the most effective means of eliminating or reducing hazards and the risks that derive from them. Acknowledging that premise—that risk reduction measures should be considered and taken in a prescribed order—represents an important step in the evolution of the practice of safety. 13.2 A major premise to be considered in applying a hierarchy of controls is that the outcome of the actions taken is to be an acceptable risk level. 13.3 Acceptable risk, as previously 8 Special Issue Prevention through Design defined, is that risk for which the probability of a hazard-related incident or exposure occurring and the severity of harm or damage that could result are as low as reasonably practicable, and tolerable in the situation being considered. 13.4 That definition requires taking into consideration: a) avoiding, eliminating or reducing the probability of a hazard-related incident or exposure occurring; b) reducing the severity of harm or damage that may result, if an incident or exposure occurs; c) the feasibility and effectiveness of the risk reduction measures to be taken, and their costs, in relation to the amount of risk reduction to be achieved. 13.5 Decision makers should understand that, with respect to the six levels of action shown in the hierarchy of controls in 13.6 that: 13.5.1 The ameliorating actions described in the first, second, and third action levels are more effective because they: a) are preventive actions that eliminate or reduce risk by design, substitution, and engineering measures; b) rely the least on the performance of personnel; c) are less defeatable by supervisors or workers. 13.5.2 Actions described in the fourth, fifth and sixth levels are contingent actions and rely greatly on the performance of personnel for their effectiveness. 13.6 The following hierarchy of controls is considered state-of-the-art. It is compatible with the hierarchy of controls in ANSI/AIHA Z10-2005. a) Eliminate or reduce risks in the design and redesign processes. b) Reduce risks by substituting less hazardous methods or materials. c) Incorporate safety devices. d) Provide warning systems. e) Apply administrative controls (work methods, training, work scheduling, etc.). f) Provide PPE. 14.0. The Logic of Taking Action in the Order Given Comments follow on each of the action elements listed in the preceding hierarchy of controls, including the rationale for listing actions to be taken in the order given. Taking actions in the prescribed order, as feasible and practicable, is the most effective means to achieve risk reduction. 14.1 Eliminate or reduce risks in the design and redesign processes 14.1.2 The theory is plainly stated. If hazards are eliminated in the design and redesign processes, risks that derive from those hazards are also eliminated. But, elimination of hazards completely by modifying the design may not always be practicable. Then, the goal is to modify the design, within practicable limits, so that the: a) probability of personnel making human errors because of design inadequacies is at a minimum; b) ability of personnel to defeat the work system and the work methods prescribed, as designed, is at a minimum Examples are designing to eliminate or reduce the risk from fall hazards; ergonomic hazards; confined space entry hazards; electrical hazards; noise hazards; and chemical hazards. 14.2 Substitution of less hazardous methods or materials 14.2.1 Substitution of a less hazardous method or material may or may not result in equivalent risk reduction in relation to what might be the case if the hazards and risks were reduced to a practical minimum through system design or redesign. Consider this example. Considerable manual material handling is necessary in a mixing process for chemicals. A reaction takes place and an employee sustains serious chemical burns. There are identical operations at two of the company’s locations. At one, the operation is re-designed so that it is completely enclosed, automatically fed, and operated by computer from a control panel, thus greatly eliminating operator exposure. At the other location, funds for doing the same were not available. To reduce the risk, it was arranged for the supplier to premix the chemicals before shipment (substitution). Some mechanical feed equipment for the chemicals was also installed. The risk reduction achieved by substitution was not equivalent to that attained by re-designing the operation. Additional administrative controls had to be applied. Methods that illustrate substituting less hazardous methods, materials, or processes for that which is more hazardous include using automated material handling equipment rather than manual material handling; providing an automatic feed system to reduce machine hazards; using a less hazardous cleaning material; reduce speed, force, amperage; reduce pressure, temperature; replace an ancient steam heating system and its boiler explosion hazards with a hot air system. 14.3 Incorporate safety devices 14.3.1 When safety devices are incorporated in the system in the form of engineering controls, substantial risk reduction can be achieved. 14.3.2 Engineered safety devices are to prevent access to the hazard by workers. They are to separate hazardous energy from the worker and deter worker error. Examples are machine guards; interlock systems; circuit breakers; start-up alarms; presence-sensing devices; safety nets; ventilation systems; sound enclosures; fall prevention systems; and lift tables, conveyors and balancers. 14.4 Warning systems 14.4.1 Warning system effectiveness relies considerably on administrative controls, such as training, drills, and the quality of maintenance, and the reactions of people. 14.4.2 Although vital in many situations, warning systems may be reactionary in that they alert persons only after a hazard's potential is in the process of being realized (e.g., a smoke alarm). Examples are smoke detectors; alarm systems; backup alarms; chemical detection systems; signs; and alerts in operating procedures or manuals. 14.5 Administrative controls 14.5.1 Administrative controls rely on the methods chosen as appropriate in relation to the needs, the capabilities of people responsible for their delivery and application, the quality of supervision, and the expected performance of the workers. Some administrative controls are personnel selection; developing and applying appropriate work methods and procedures; training; supervision; motivation, behavior modification; work scheduling; job rotation; scheduled rest periods; maintenance; management of change; investigations; and inspections. 14.5.3 Achieving a superior level of effectiveness in all of these administrative methods is difficult and not often attained. 14.6 Provide PPE 14.6.1 The proper use of personal protective equipment relies on an extensive series of supervisory and personnel actions, such as the identification of the type of equipment needed, its selection, fitting, training, inspection, maintenance, etc. Examples include safety glasses; face shields; respirators; welding screens; safety shoes; gloves; and hearing protection. 14.6.2 Although the use of personal protective equipment is common and is necessary in many occupational situations, it is the least effective method to deal with hazards and risks. Systems put in place for their use can easily be defeated. 14.6.3 In the design processes, one of the goals should be to reduce reliance on personal protective equipment to a practical minimum, applying the ALARP concept. 14.7 For many risk situations, a combination of the risk management methods shown in the hierarchy of controls is necessary to achieve acceptable risk levels. But the expectation is that consideration will be given to each step in a descending order and that reasonable attempts will be made to eliminate or reduce hazards and their associated risks through steps higher in the hierarchy before lower steps are considered. A lower step is not to be chosen until practical applications of the preceding level or levels are exhausted. 14.8 A yet unpublished document, MIL-STD-882E, includes provisions that further explain the thought process that should govern when the hierarchy of controls is applied. Excerpts follow from the “System safety mitigation order of precedence” in 882E. 14.8.1 In reducing risk, the cost, feasibility and effectiveness of candidate mitigation methods should be considered. In evaluating mitigation effectiveness, an order of precedence generally applies as follows. a) Eliminate hazard through design selection. Ideally, the risk of a hazard should be eliminated. This is often done by selecting a design alternative that removes the hazard altogether. b) Reduce mishap risk through design alteration. If the risk of a hazard cannot be eliminated by adopting an alternative design, design changes should be considered that reduce the severity and/or the probability of a harmful outcome. c) Incorporate engineered safety features (ESF). If unable to eliminate or adequately mitigate the risk of a hazard through a design alteration, reduce the risk using an ESF that actively interrupts the mishap sequence. continued on page 10 By Design 9 continued from page 9 d) Incorporate safety devices. If unable to eliminate or adequately mitigate the hazard through design or ESFs, reduce mishap risk by using protective safety features or devices. e) Provide warning devices. If design selection, ESFs, or safety devices do not adequately mitigate the risk of a hazard, include a detection and warning system to alert personnel to the presence of a hazardous condition or occurrence of a hazardous event. f) Develop procedures and training. Where other risk reduction methods cannot adequately mitigate the risk from a hazard, incorporate special procedures and training. Procedures may prescribe the use of personal protective equipment. 15.0 Conclusion 15.1 It would be folly for safety professionals to ignore the impact of the Prevention through Design/Safety through Design movement on their knowledge needs. It is becoming evident that it’s all about risk, about being able to identify and analyze hazards and assess the risks deriving from them. The entirety of purpose of those responsible for safety, whatever their titles, is to deal with hazards so that the risks deriving from those hazards are acceptable 15.2 This paper is a primer on PtD/Safety through design. An extensive list of references follows for those who would like to continue their education. References ANSI/AIHA Z10-2005. Occupational Health and Safety Management Systems. Fairfax, VA: American Industrial Hygiene Association, 2005. www.aiha.org/marke tplace.htm. ANSI/PMMI B155.1-2006. Safety Requirements for Packaging Machinery and Packaging-Related Converting Machinery. Arlington, VA: Packaging Machinery Manufacturers Institute, 2006. ANSI B11.TR3-2000. Risk Assessment and Reduction: A Guide to Estimate, Evaluate and Reduce Risks Associated with Machine Tools. McLean, VA: AMT, The Association for Manufacturing Technology, 2000. “ASSE Position Paper On Designing for Safety”. Approved by the Board of Directors in 1994. Des Plaines, IL: ASSE. Aviation Ground Operation Safety Handbook (6th ed.) Itasca, IL: National Safety Council, 2007. Clemens, P. “A Compendium of Hazard Identification and Evaluation Techniques for System Safety Application.” Hazard Prevention, March/April, 1982. Christensen, W.C. & Manuele, F.A. Safety Through Design. Itasca, IL: National Safety Council Christensen, W.C. “Retrofitting for Safety: Career implications for SH&E personnel.” Professional Safety, May 2007. Christensen, W.C. Safety Through Design: Helping design engineers answer10 key questions. Professional Safety, March 2003. Failure Mode and Effects Analysis: A Guide for Continuous Improvement for the Semiconductor Equipment Industry. Technology Transfer #92020963A-ENG. Austin, TX: International SEMATECH, 1992. Available at www.sematech.org. Guidance Document for Incorporating Risk Concepts into NFPA Codes and Standards. Quincy, MA: The Fire Protection Research Foundation, 2007. Guide to Use of the Management Oversight and Risk Tree. SSDC-103. Washington, DC: Department of Energy, 1994. Guidelines for Hazard Evaluation Procedures, 2nd ed. with worked examples. A Center for Chemical Process Safety 1992 publication, now available through John Wiley & Sons, Hoboken, NJ. ISO 12100-1. Safety of Machinery: Basic concepts, general principles for design. Part 1. Basic terminology, methodology. Geneva, Switzerland: International Organization for Standardization, 2003. ISO 14121. Safety of Machinery: Principles for risk assessment. Geneva, Switzerland: International Organization for Standardization, 1999. Main, B. Risk Assessment: basics and benchmarks. Ann Arbor, MI: Design Safety Engineering Inc, 2004. Main, B. “Risk assessment is coming. Are you ready?” Professional Safety, July 2002. Main, B. “Risk assessment: A review of the fundamental principles.” Professional Safety, December 2004. Manuele, F.A. Advanced Safety Management: Focusing on Z10 and Serious Injury Prevention. Hoboken, NJ: John Wiley & Sons, 2007. Manuele, F.A. “ANSI/AIHA Z102005: The new benchmark for safety management systems.” Professional Safety, February 2006. Manuele, F.A. On the Practice of Safety, 3rd ed. Hoboken, NJ: John Wiley & Sons, 2003. Manuele, F.A. “Risk Assessments and Hierarchies of Control.” Professional Safety, May 2005. MIL-STD-882D. Standard Practice for System Safety. Washington: DC: Department of Defense, 2000. Also at http://www.safetycenter.navy.mil/instructions/osh/milstd882d.pdf#search='MILSTD882D’. Potential Failure Mode and Effects Analysis. Southfield, MI: Automotive Industry Action Group, 3rd ed., 2001. SFPE Engineering Guide to Fire Risk Assessment. Bethesda, MD: The Society of Fire Protection Engineers, 2006. Stephans, R. & Talso, W.W., eds. System safety analysis handbook: a sourcebook for safety practitioners. Albuquerque, NM: New Mexico Chapter, System Safety Society, 1997. Stephans, R.A. System safety for the 21st century. Hoboken, NJ: John Wiley & Sons, 2004 Swain, A.D. “Work situation approach to improving job safety.” Albuquerque, NM: Sandia Laboratories. Vincoli, J.W. Basic guide to system safety. Hoboken, NJ: John Wiley & Sons, 1993. ANSI/AIHAZ10 Is Here ANSI/AIHA Z10: Occupational Health and Safety Management Systems 10 Special Issue Prevention through Design Call ASSE at (847) 699-2929 or visit www.asse.org. ADDENDUM A The Risk Assessment Process 1) Data gathering Injury and proactive data 2) Set the limits/scope of the strategy leadership team sponsorship 3) Develop and charter risk reduction team Reevaluate tasks and hazards 4) Identify tasks and hazards Identify current controls 5) Assess risk—Initial risk scoring system 6) Reduce risk Hazard control hierarchy 7) Assess risk—Residual risk scoring system No Test/verify current controls Identify new controls Residual risk acceptable? Yes 8) Results/documentation Evaluation complete 10) New hazard ID 9) Controls measurement system By Design 11 ADDENDUM B Initial Hazard Analysis & Risk Assessment Worksheet 12 Special Issue Prevention through Design ADDENDUM C Potential Failure Modes & Effects Analysis Sequence Subsystem Function Reqt’s Potential Effect(s) of Failure Potential Failure Mode What are the effect(s)? S E V C l a s s Potential Cause(s)/ Mechanisms of Failure O D Responsibility c Current e R. Recommended & Target c t P. Controls Action(s) Completion u e N. Date r Prevention Direction c How bad is it? Action Results Actions Taken S O D R. e c e P. v c t N. What can be done? •Design changes What are the functions, features or requirements? •Process changes What are the causes? How often does it happen? What can go wrong? •Special controls •Changes to standards, procedures or guides •No function •Partial/over/ degraded function •Intermittent function •Unintended function How can this be prevented and detected? How good is the method at detecting it? Note: Reprinted from Potential Failure Mode & Effect Analysis (3rd ed.) with permission of DaimlerChrysler, Ford and GM Supplier Quality Requirements Task Force. By Design 13
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